On Point: 40. TPRs

State v. D.H., 2025AP2668, 4/10/26, District I (ineligible for publication); case activity

Potentially reviving an issue many may have thought already settled, COA upholds the circuit court’s order for plea withdrawal in a case involving a deficient colloquy regarding the dispositional burden of proof in a TPR case.

State v. V.T., 2025AP1338-40, 3/23/26, District I (ineligible for publication); case activity

In an interesting ineffectiveness appeal, COA confronts clear-cut deficient performance but declines V.T.’s invitation to depart from the Strickland prejudice standard.

State v. B.A.J., 2025AP1476-77, 4/2/26, District I (ineligible for publication); case activity

In a case that demonstrates the high burden that parents must satisfy to withdraw their pleas, COA affirms despite also acknowledging the “questionable” nature of this mentally ill parent’s plea.

Sawyer County Health & Human Services v. D.K., 2025AP2832, 3/12/26, District III (ineligible for publication); case activity

The COA reversed the order terminating “Daniel’s” parental rights after summary judgment was granted at the grounds phase because genuine issues of material fact exist whether the County made reasonable efforts to provide services.

Jefferson County DHS v. G.J.J., 2025AP2491, 3/5/26, District IV (ineligible for publication); case activity

While G.J.J. gets closer than most–and his arguments even give COA “pause”–ultimately, the deferential standard of review applicable to dispositional decisions results in affirmance.

J.R.P. v. W.P.M., 2024AP1535, 2/19/26, District IV (ineligible for publication); case activity

In a rare sufficiency challenge pursued by the petitioner, COA applies a deferential standard of review and affirms.

State v. L.Z., 2025AP2731-32, 2/17/26, District I (ineligible for publication); case activity

Although L.Z. tries to capitalize on certain statements in the court’s oral ruling as giving a foothold for her appellate challenge, the standard of review means the argument attacking a discretionary decision goes nowhere.

Chippewa County v. C.F., 2025AP1744, 1/21/26, District III (ineligible for publication); case activity

C.F. appeals the order terminating her parental rights to her son, arguing the circuit court erred by granting the county’s motion for partial summary judgment as to grounds. COA agrees that the order denying her visitation did not give adequate notice of the conditions she needed to meet in order to be granted visitation.

Marquette County DHS v. J.J., 2025AP1963, 1964 & 1965, 12/18/25, District IV (ineligible for publication); case activity

J.J. stipulated to the existence of grounds for termination but contested disposition. He now appeals the orders terminating his parental rights to three of his children, arguing that the circuit court erred because it based its termination decision in part on his poverty. COA concludes that the court did not erroneously exercise its discretion and affirms.

Sheboygan County DH&HS v. Z.N., 2025AP1817, 11/7/25, District II (ineligible for publication); case activity

In an unpublished but citable case, COA clarifies there is no requirement that respondent appear in person for a voluntary termination of parental rights in an ICWA case and reverses the circuit court’s default finding.